Comments on 114 Liberty cleaning and monitoring documentation, February 2003

NYC 9/11 Public Portal Document

Table 1: Sampling and Analytical Methods Parameter Description Sampling Analytical Method Maximum Methodology Turnaround Time Lead Wipe samples HUD Appendix 13.1 EPA Method SW-846-6010B 1 day PAHs Wipe samples ASTM D6661-01 ASTM-6661-01 14 days EPA SW-846-8270C Dioxin Wipe samples ASTM 6661-01 ASTM 6661-01 14 days EPA Method SW-846-8290 Fibrous Air samples NIOSH 7400 NIOSH 7400, 3 days Glass Counting Method "B" Crystalline Air samples NIOSH 7500 NIOSH 7500 (XRD) 14 days Silica Asbestos Air samples Collection using Asbestos Fiber Analysis by 1 day NIOSH 7400 Transmission Electron Microscopy (TEM) Performed by EPA 40 CRF Part 763 Final Rule (AHERA) [see Attachment 1 ] and NIOSH 7400 (PCM)

Asbestos Air Sample Collection and Analysis

1. All asbestos air sampling methodologies shall be in accordance with the applicable sections of Title 15, Chapter 1 of the Rules of the City of New York and AHERA. (see reference in Table 1)

2. Asbestos air samples shall be analyzed in accordance with EPA 40 CRF Part 763 Final Rule (AHERA) using a transmission electron microscope (TEM) and reported as shown in Attachment 1. For the TEM analysis, two size fractions should be reported, a fraction that represents fibers >0.5 microns and a fraction that represents fibers >5 microns. The fraction that represents the fibers >5 microns is considered to be the PCM equivalent (i.e., PCMe) that should be compared to the primary clearance value of 0.0009 s/cc. In addition, the asbestos air samples shall be analyzed in accordance with NIOSH 7400 for standard PCM analysis. These results shall be reported on a separate sheet. The detection limit shall be 0.0004 f/cc.

3. A turnaround time of 24 hours is required for all samples.

Asbestos Air Monitoring

1. Five (5) pre-cleanup air samples shall be collected outside but in the general vicinity of the work site. Samplers shall be placed in reasonable proximity to the building and away from obstructions, vents, and drafts that may unduly affect airflow.

2. Five (5) air samples shall be collected per day during cleanup activities. The flow rate shall be set at 5-6 liters per minute. A minimum sampling volume of 3600 liters shall be collected. [THE NUMBER OF SAMPLES PER DAY SEEMS QUITE LOW, GIVEN THEY WILL BE WORKING AROUND THE CLOCK.]

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